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#1496404 - 01/18/11 05:46 PM
Re: Follow Up SAR? - A (maybe) dumb question
CompliKat
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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A follow-up SAR is designed to report on continuing suspicious activity of the type already reported. IMO, your suspicious activity ended with the closing of the loans, unless there is anything about the payments (large cash payments, for example) that you suspect.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1497831 - 01/20/11 06:42 PM
Re: Follow Up SAR? - A (maybe) dumb question
CompliKat
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10K Club
Joined: Jul 2001
Posts: 84,368
Galveston, TX
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What - you meant what little hair that he has left is "salt and pepper"? Sorry, John - couldn't help it...
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1497881 - 01/20/11 07:20 PM
Re: Follow Up SAR? - A (maybe) dumb question
rlcarey
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Member
Joined: Dec 2009
Posts: 96
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#1498819 - 01/21/11 08:58 PM
Re: Follow Up SAR? - A (maybe) dumb question
CompliKat
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10K Club
Joined: Jul 2001
Posts: 84,368
Galveston, TX
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I would ask why? There was loan fraud at the time of loan being made. Filing every 90 days just because the loan is still outstanding does not make any sense to me. If you obtained a correct and valid TIN, what on-going violation of law are you going to cite?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1498828 - 01/21/11 09:07 PM
Re: Follow Up SAR? - A (maybe) dumb question
CompliKat
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Same question worded a bit differently: What exactly are you going to put in the narrative? If the suspicious activity has not continued...
Rather than continuing to shop for an answer, just call the FinCEN helpline & go with what they say.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#1503951 - 02/02/11 05:33 PM
Re: Follow Up SAR? - A (maybe) dumb question
CompliKat
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Junior Member
Joined: Oct 2006
Posts: 41
Bristol, PA
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I have a question about the 90 day filing and have been looking everywhere. I came here hoping someone was talking about it. Everything just states filing a report at least every 90 days. Every 90 days from what date? I am assuming the date you filed the last report. My other choice would be using the date or date range of the suspicious activity. Anyone's thoughts? I'm trying to make a log so I can remember to do the 90 day filing. I want to mark the date when to review the report again and want to leave myself enough time to gather information, review it, make a decision and get it filed or not. Thanks
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#1503953 - 02/02/11 05:35 PM
Re: Follow Up SAR? - A (maybe) dumb question
mep
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Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
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90 days from when the previous SAR was filed.
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#1503954 - 02/02/11 05:36 PM
Re: Follow Up SAR? - A (maybe) dumb question
mep
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Power Poster
Joined: Oct 2009
Posts: 3,927
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For convenience, I use the last day of the month 90 days from the date of last filing. The filing is usually very close to the date of the suspicious activity, so that works for me. I use a formula in my spreadsheet that works off the last filing date and tells me the end of the month 90 days forward. This way I do all the SAR re-reviews at the end of each month rather than at the exact 90 day mark; it just makes it easier to manage my time.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#1503991 - 02/02/11 05:55 PM
Re: Follow Up SAR? - A (maybe) dumb question
Doug Hendrickson
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Junior Member
Joined: Oct 2006
Posts: 41
Bristol, PA
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Thanks for both your answers. I have a better understand and grip on what I need to do. Thanks again.
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#1507036 - 02/09/11 12:36 PM
Re: Follow Up SAR? - A (maybe) dumb question
CompliKat
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Power Poster
Joined: Oct 2003
Posts: 2,548
Southeast
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Complikat,
If I were you, I would contact FinCEN two more times. Then I would take the best two out of three. My guess is that you would not get the same answer twice. If what they say is true, we will all be filing a lot of totally useless SARS forever unless we choose to close out the relationship.
Better yet, contact your regulator for their opinion. Somewhere there has to be somebody with some common sense.
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Politicians are like diapers. They need to be changed often and for the same reason.
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#1507279 - 02/09/11 04:51 PM
Re: Follow Up SAR? - A (maybe) dumb question
Retread
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Agree with Retread; call FinCEN back. Ask for a supervisor. This is not a judgment call.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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